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    <title>2022 (4) TMI 249 - KERALA HIGH COURT</title>
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    <description>Entitlement to the Amnesty Scheme, 2020 arose where modified assessment and penalty orders were served only after the taxpayer had sought them to exercise the scheme option. The taxpayer attempted to file the option within the available statutory period, but portal access was denied because the system treated the deadline as expired. As the failure resulted from system denial rather than any omission by the taxpayer, refusal to accept the option was contrary to the scheme. The taxpayer was entitled to claim amnesty, and the option was required to be accepted.</description>
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      <description>Entitlement to the Amnesty Scheme, 2020 arose where modified assessment and penalty orders were served only after the taxpayer had sought them to exercise the scheme option. The taxpayer attempted to file the option within the available statutory period, but portal access was denied because the system treated the deadline as expired. As the failure resulted from system denial rather than any omission by the taxpayer, refusal to accept the option was contrary to the scheme. The taxpayer was entitled to claim amnesty, and the option was required to be accepted.</description>
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